United States securities and exchange commission logo
July 20, 2023
Calvin Kung
Chief Executive Officer
Finnovate Acquisition Corp.
The White House
20 Genesis Close, George Town
Grand Cayman, Cayman Islands
Re: Finnovate
Acquisition Corp.
Form 10-K for the
Fiscal Year ended December 31, 2022
Filed April 13,
2023
File No. 001-41012
Dear Calvin Kung:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comment. In our comment, we may ask
you to provide us
with information so we may better understand your disclosure.
Please respond to this comment within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this comment, we may have additional comments.
Form 10-K for the Fiscal Year ended December 31, 2022
Risk Factors, page 30
1. We note that you have
risk factor disclosures on pages 17 and 18 of the Definitive Proxy
Statement that you
filed on April 28, 2023, regarding the possibility that you may be
deemed a foreign
person under the regulations administered by the Committee on
Foreign Investment in
the United States (CFIUS), because your Sponsor is controlled by
non-U.S. persons. We
believe you should provide similar risk factor disclosures in your
periodic reports,
having a clear focus on the prospect of completing your initial business
combination and the
concerns referenced in each of the following points.
Discuss the risk
to investors that you may not be able to complete an initial business
combination with a
U.S. target company if the transaction becomes subject to review
by a U.S.
government entity, such as CFIUS, or ultimately prohibited.
Calvin Kung
Finnovate Acquisition Corp.
July 20, 2023
Page 2
Explain that as a result, the pool of potential targets with
which you could complete
an initial business combination may be limited.
Explain that the time necessary for government review of the
transaction or a
decision to prohibit the transaction could prevent you from
completing an initial
business combination and require you to liquidate.
Discuss the consequences of liquidation to investors, such as
the losses of the
investment opportunity in a target company, any price
appreciation in the combined
company, and the warrants that would expire worthless.
Please submit the disclosures that you propose to include in your
periodic reports.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
You may contact Yong Kim, Staff Accountant, at 202-551-3323 or Gus
Rodriguez, Staff
Accountant, at 202-551-3752 with any questions.
FirstName LastNameCalvin Kung Sincerely,
Comapany NameFinnovate Acquisition Corp.
Division of
Corporation Finance
July 20, 2023 Page 2 Office of Energy
& Transportation
FirstName LastName